IN THE COURT OF JUDICIAL MAGISTRATE III AT []

Cr. Bail Application No: _______ of 2022

[] S/o [],
R/o [],
Now Confined at
Central Prison, [] …………………..……………………………………............. Applicant.

V/S

The State ……………………………………………………………..... Respondent.

FIR No:X/2018
U/S 504, 34 PPC.
P.S A-Section.

BAIL APPLICATION U/S —— Cr P.C.

It is prayed on behalf of the above named applicants that this honourable court may be pleased to grant
bail to the above named applicants on consideration of the following facts and grounds.
Facts
The facts of the prosecution case in a nutshell are that the complainant Waheed Khan lodged the
FIR at the P.S stating therein that on the day of incident he along with his PWs was available at
his house when at 5:00PM he heared cries out side of his house, he went to see what has
happened where he saw the above named applicant abusing the complainant on which he asked
him to refrain from abusing but he continued to use abusive language against him afterwards
upon intervention of the neighbourers he went away, the motive behind the incident is said to be
quarrel in between chidren of both the parties. The complainant went at the P.S and registered
the present FIR at midnight. After registration of FIR investigation ensued and the applicant was
arrested and now matter has been challaned. Hence this bail application.

Grounds
1) That the applicant is innocent and has been falsely implicated.

2) That there is 6 hours delay in lodging the FIR for which no any plausible explanation has
been given by the complainant.

3) That the alleged offence is bailable and in such like cases bail is right of the accused.

4) That bail cannot be withheld in bailable offences.

 5) That the case has been challaned and applicant/accused is not required to the police for
the purpose of investigation.

6) That the applicant/accused is not previous convict or hardened criminal.

7) That the applicant is ready to furnish solvent surety to the satisfaction of this Honourable
Court.

8) That it will be in the interest of justice if the application is allowed.

Larkana Advocate,
Dated: 11.03.2018 For the applicant/accused.